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PETER OAKES
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    Peter Oakes is an experienced anti-financial crime, fintech and board director professional.

    He has served in senior roles at central banks (Ireland & Saudi Arabia) and financial regulators (UK and Australia).

    Peter is an experienced board director of regulated finserv & fintech firms and advisor to regtech firms.

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Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions

10/10/2020

 
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Download Report - The Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions Market developments and financial stability implications 

One for all the #regtech and #suptech ambassadors / champions in the network (and you may have spotted it) - Use of Supervisory and Regulatory Technology by Authorities and Regulated Institutions covering:
  • Drivers of SupTech and RegTech developments
  • Benefits, challenges and risks for authorities and regulated entities
  • SupTech and RegTech strategies, market interaction and monitoring developments
  • SupTech resource considerations
  • Applications of new technologies by regulated institutions & authorities
  • Future technology use by the regulator
  • Ethics of using AI models for supervision
  • Case studies and examples

As you will see in the images below and in the report, less than 50% of supervisory authorities responding to the FSB survey had a Chief Data Officer or equivalent.  Areas where new RegTech tools and uses for data have been developed post 2016 are:

  • Risk reporting
  • Stress testing
  • Microprudential reporting
  • Other Macroprudential reporting
​
Whereas pre-2016, the supervisory authorities were focused on:
  • Fraud Detection
  • AML/CFT
  • KYC & Identity and Verification
  • Risk assessment
  • Risk management

Future technology use by the regulator 
I thought the section 9.2 Future technology use by the was regulator interesting. The FSB reports that rapid changes to the financial landscape and evolving market structure could be accompanied by changes in supervisory surveillance techniques. [Oakes - Ok so that is relatively obvious]

85% + of survey respondents expect that the continued evolution of available technologies will result in changes to supervisory processes, with 68% expecting this to be a considerable change. However, authorities expressed concern that undue reliance on SupTech tools could lead to misplaced focus on areas where risks can be easily measured. [Oakes - so just because you can do something doesn't mean you should do it]. This may deflect attention from areas of concern that are not as easily given to quantifiable measurement [Oakes - so true].

Retaining a forward-looking human based supervisory process
Thus while authorities may recognise the importance of integrating technology into their supervisory approaches, they could also acknowledge the importance of retaining a forward-looking human based supervisory process. The modern supervisory philosophy in most jurisdictions surveyed is based on predictive and human judgement-based oversight of regulated institutions. Technology offers the opportunity to automate routine tasks, develop new analytical techniques and provide better information. Using tools such as AI and ML to analyse increasing volumes of regulatory data provides opportunities for authorities to shift their focus to those aspects where humans excel over machines, e.g. judgement-based decision making. [Oakes- couldn't add anything further to that].

Cases Studies
I also recommend a read of Annex 1 where the Case studies and examples are contained.  There are case studies from 26 supervisory authorities:
  1. De Nederlandsche Bank - Becoming a smart supervisor
  2. European Central Bank - Supervisory Technology Hub
  3. European Central Bank - ECB’s Virtual lab
  4. Bank of England - Unstructured data extraction and analysis using ML
  5. People’s Bank of China - Off-site Payment Transactions Supervision Based on API and AI
  6. Bank of England, Financial Conduct Authority - Digital Regulatory Reporting (DRR)
  7. European Securities and Markets Authority - Web scraping, NLP and analysis of Key Information Documents
  8. European Central Bank - Machine-reading of Fit and Proper Questionnaire
  9. China Banking and Insurance Regulation Commission - Multi-party secure computing (credit field)
  10. Banco de España - Use of NLP in relation to ESG disclosures in Spain
  11. Banco de España - Tools for detection of mis-selling in Spain
  12. Monetary Authority of Singapore - Network Analysis for STRs
  13. Banca d’Italia - Anomaly measurement in transactions using Big Data
  14. Commissione Nazionale per le Società e la Borsa (CONSOB) - Market Surveillance
  15. European Central Bank - Early Warning System for Less Significant Institutions
  16. European Central Bank SREP – Truffle Search Analytics for structured text documents
  17. Monetary Authority of Singapore - Predictive modelling to identify representatives at higher risk of misconduct
  18. Monetary Authority of Singapore - Text analysis of audited financial statements
  19. Monetary Authority of Singapore - Data analytics for inspections
  20. European Central Bank - Sentiment analysis 
  21. European Central Bank - Network Analytics
  22. Banque de France/ACPR - Augmented supervisor
  23. Banque de France/ACPR - Advanced network analysis for banking supervision purposes
  24. Federal Reserve Board of Governors - NLP for continuous monitoring, web searches and COVID-19 monitoring
  25. Bank for International Settlements - BIS Bulletins
  26. Bank of England - Policy Response Tracker
  27. De Nederlandsche Bank - COVID-19 SAS-VA Dashboard
  28. Monetary Authority of Singapore - Monitoring and enforcement of safe distancing measures 

Source:
https://www.fsb.org/2020/10/the-use-of-supervisory-and-regulatory-technology-by-authorities-and-regulated-institutions-market-developments-and-financial-stability-implications/

​https://www.fsb.org/2020/10/the-use-of-supervisory-and-regulatory-technology-by-authorities-and-regulated-institutions-market-developments-and-financial-stability-implications/


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Spain - Collapse of half a billion euro money laundering and seizure case

10/10/2020

 
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Here's one for the #moneylaundering typology case studies for #MLROs as part of regulatory training requirements!
 
Relates to the collapse of major investigation into the Kinahan cartel and more than half a billion euros- particularly €500,000,000 stash of cars, properties & cash handed back to the accused by a Spanish judge after collapse of money laundering case.

Continue reading at CompliReg by clicking here.


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Aussie Bank Westpac to be hit with $1bn money laundering fine? (Peter Oakes)

16/5/2020

 
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​Australian Bank giant Westpac is expecting to fork out more than $1 billion as a result of its money laundering scandal and admitting to 23 million anti-money laundering breaches.

It's not just story about culture, conduct risk and financial crime risks.  Far more importantly, it is a story of shame, leadership failure and financial pain for Westpac and relief for another Aussie bank.
 
The fine would be the biggest corporate fine in Australian history. Westpac has revealed it expects the ongoing AUSTRAC investigation will cost it $1.03 billion.  Such a fine will represent about 15% of the bank's 2019 profit.
 
Shame: In November last year AUSTRAC, the entity responsible for preventing financial crimes, said the bank had violated anti-money laundering and counter-terrorism laws more than 23 million times (which the bank admits), allowing money tied to child exploitation in south-east Asia to flow freely. For example, Westpac's system was used by paedophiles to send money to the Philippines to pay for child abuse material without raising any red flags.   Notwithstanding Westpac's admission, the bank is not going down without a fight.  In the 57-page defence document filed with the court, Westpac denied AUSTRAC'S accusation that it failed to identify activity indicative of child exploitation risks.
 
Leadership Failure: The scandal brought down Westpac's leadership, forcing the resignation of chief executive Brian Hartzer and the early retirement of chairman Lindsay Maxsted.
 
Financial Pain: Last year Australian financial press reported that a penalty or settlement of $2 billion or $3 billion would see its CET1 ratio falling below 10.5% meaning the bank would be forced into another equity raising. And the trouble doesn't stop there for Westpac as the corporate regulator, ASIC, is probing into Westpac's previous $2.5 billion equity raise.
 
Relief: Commonwealth Bank will be delighted to pass the mantle of the indignity of Australia's current money laundering record fine of $700 million to Westpac (Commonwealth Bank was fined for systemically failing to report around 54,000 suspicious transactions made through its "intelligent deposit machines").
 
If you want more on the story from the media, there are updates on an almost weekly basis  - soon I guess daily basis.  Just use this link to keep track of the story:  "Westpac Austrac money laundering fine".

And add case to your case studies and typologies in your AML / CTF training for everything from CDD, transaction monitoring, risk assessment, culture, condusct risk and (lack of) crisis management.

Peter Oakes, Founder, CompliReg
​
Peter Oakes is an experience anti-financial crime, fintech and board director professional.  He served as Ireland's first Director of Enforcement and Financial Crime Supervision at the Central Bank of Ireland (2010-2013) in the aftermath of the financial crisis, leading the investigation and enforcement efforts into the Irish banking industry.  Peter is a regular contributor to, and moderator and panel member at, ACAMS events.
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